On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource...more
The EPA (or “Agency”) is seeking public input and data regarding the potential future designation of seven per- and polyfluoroalkyl substances (“PFAS”) under the Comprehensive Environmental Response, Compensation, and...more
The Environmental Protection Agency (“EPA”) issued a long-anticipated proposal to designate two per- and polyfluoroalkyl substances (“PFAS”) as hazardous substances under the federal Superfund law known as the Comprehensive...more
In the latest development surrounding PFAS, EPA has published a direct final rule endorsing use of the newly updated ASTM E1527-21 standard for Phase I Environmental Site Assessments (“Phase Is”)...more
In 2021, there was sustained and fast-paced executive action from the Biden administration focused on emphasizing and addressing the environmental and human health effects of per- and poly-fluoroalkyl substances, more...more
1/26/2022
/ CERCLA ,
Clean Water Act ,
Drinking Water ,
Environmental Protection Agency (EPA) ,
Infrastructure Investment and Jobs Act (IIJA) ,
Joe Biden ,
PFAS ,
Recordkeeping Requirements ,
Reporting Requirements ,
Safe Drinking Water Act ,
Toxic Chemicals ,
Toxic Substances Control Act (TSCA) ,
Wastewater
The Environmental Protection Agency (“EPA”) launched its PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024 (the “Roadmap”) on October 18, 2021. EPA presents the Roadmap as a comprehensive approach outlining the...more
EPA announced plans for two separate rulemaking processes that would expand liabilities for PFAS wastes. The first — a rulemaking process to add certain PFAS chemicals as “hazardous constituents” under the Resource...more
On July 12, 2021, Physicians for Social Responsibility (“PSR”) issued a highly speculative report that raised concerns about a chemical approved by the EPA in 2011 for use in hydraulic fracturing fluid that “might” degrade...more
Per- and polyfluoroalkyl substances, known collectively as “PFAS,” are synthetic organic compounds that do not occur naturally in the environment. Some of these chemicals have been used for decades in a wide variety of...more
In recent years, there has been no shortage of interest and commentary dedicated to a group of chemicals known collectively as PFAS. As one example, the potential designation of certain PFAS — PFOA and PFOS (perfluorooctanoic...more
On February 5, 2021, the acting head of the U.S. Department of Justice (“DOJ”) division that brings environmental enforcement cases issued a memo revoking nine policy directives from the prior administration, including...more
PFAS regulation is one of the hot environmental topics and a key issue to watch during this next year. In this series of posts, V&E will address the increasing regulatory attention concerning a group of chemicals known as...more
While news stories and campaign rhetoric can frequently create expectations of immediate shifts after a change in administration, most changes happen slowly in the federal government, and constraints on resources means that...more
1/28/2021
/ Biden Administration ,
CERCLA ,
Chemicals ,
Environmental Justice ,
Environmental Protection Agency (EPA) ,
PFAS ,
PHMSA ,
Risk Management ,
Trump Administration ,
Volatile Organic Compounds (VOC) ,
Wastewater
PFAS regulation is one of the hot environmental topics and a key issue to watch during this next year. In this series of posts, V&E will address the increasing regulatory attention concerning a group of chemicals known as...more